Subject: File No. S7-08-09
From: William Baker

August 19, 2009

I feel any uptick rule is unfair in principle. In a perfect world, short sellers would play on a level field with long buyers. On the other hand, I consider market manipulation to be a greater evil than unfair treatment of short sellers.

I think it would be fair to not have an uptick rule when the markets are functioning normally and have some sort of trigger mechanism to limit or at least slow down the damage that a pool can inflict. The trigger should be applied intelligently, with the most stringent controls on low-liquidity stocks, which are the most easily manipulated. Highly liquid stocks should be on a much longer leash because it's so much harder to manipulate their prices.

Thank you for your attention.

William Baker
Individual investor